MCA MUSIC, INC.’s  - PRIVACY POLICY

Date of last revision: 1^st September 2008

MCA MUSIC , INC. ("MCA" or “we”) respects the privacy of the individuals it deals with.  "Personal information" is information or opinion about an individual that identifies the individual, or from which it is reasonably possible to determine the individual’s identity.

This Policy outlines the types of personal information MCA  collects and explains how it collects, uses, discloses and holds that information.  The Policy also explains how you can gain access to personal information that MCA  holds about you and provides contact details for MCA .  Finally, the Policy sets out the way MCA  handles personal information online (i.e. on the internet) and how MCA  uses and discloses personal information that it collects about individuals it deals with in the context of its business activities and relationships (our "business contacts").

This privacy policy applies to all MCA and Universal Music Group  websites including, but not limited to, GetMusic.

1. How is Personal Information Used?

MCA is part of the Universal Music Group which is one of the largest producers and distributors of entertainment goods and services.  For the purposes of this Policy, these are referred to as "our goods and/or services".

The primary purpose for which   MCA collects personal information is so that we can provide you with our goods or services and provide you with information in relation to our goods or services.   MCA also uses your personal information for purposes incidental to these purposes including, without limitation, for the purpose of managing its relationship with you, communicating with you effectively and identifying which of our goods and services may interest you in the future.

 MCA does not collect information it does not need.  For example,   MCA does not collect sensitive information (such as information about your health or political beliefs) because it does not need it in order to provide you with our goods or services.

2. What Personal Information does MCA  Collect?

If you ask MCA  to provide you with our goods or services (including signing up to join one of its clubs, submitting a competition entry form, or choosing to receive promotional information),  MCA may ask you to provide your name and contact details such as telephone number, postal address and email address.  MCA  may also ask you for additional information including, but not limited to, your age and entertainment preferences (e.g. what type of music you prefer).

You can refuse to provide MCA  with the personal information that it requests from you.  However, if you do not provide MCA  with the personal information it requests,  MCA  may not be able to provide you with our goods or services.

If at any time you do not wish to be notified about goods, services or promotions offered by MCA , or if you do not wish to receive any further communications from  MCA, you can opt-out of any, or all,  MCA communications by directly contacting  MCA. Details of how to contact  MCA are set out in section 9 below.

3. How does MCA Collect Personal Information?

 MCA collects personal information in a number of different ways.  The most common ways in which  MCA collects personal information, and the purposes for which that information is collected, are as follows:

–                 Personal information is collected from application forms (including on  MCA websites) when individuals apply to become members of clubs run by  MCA.  This information is collected for the purpose of providing news, information, offers and other services to members in accordance with the terms and conditions of the club.

–                 Personal information is collected from competition entries and other promotions, for the purpose of running the competition or promotion and contacting the winner(s), and, if entrants/applicants do not tell MCA  otherwise, for the purpose of sending information, news and offers in relation to our goods and services.

–                 Personal information is collected from order forms when MCA 's goods and services are ordered by distributors and retailers, for the purpose of fulfilling the order and delivering the goods, and to maintain its relationship with the individual concerned.  Personal information collected in this context may include credit, charge or debit card details.  If you provide this additional credit information it will only be used for the purposes of purchasing our goods or services.

–                 Personal information is collected from online order forms when ’s MCA’s goods or services are ordered by individuals, for the purpose of fulfilling the order and delivering the goods, and to maintain its relationship with the individual concerned.  Personal information collected in this context may include credit, charge or debit card details.

–                 Personal information is collected from telephone, email, written and in-person enquiries directed to  MCA, for the purpose of responding to the enquiries.

<!--[if    –                Personal information may be collected from  MCA websites through automatic processes such as cookies, as discussed in section 8 below.

4. Will Personal Information be Given to Anyone Else?

Generally,  MCA will not disclose personal information to individuals or organisations outside  MCA without your consent.  However, in the circumstances described below, personal information may be disclosed outside  MCA.

(a) Outsourcing

From time to time,  MCA may provide information to other companies within the Universal Music Group  and to other companies outside the said grouo that perform certain functions on its behalf.  Any personal information transferred between  Universal Music Group companies in such circumstances will be handled in accordance with this Policy. MCA may also disclose personal information to third parties to whom it contracts out specialised functions (e.g. mailing houses, printing companies and event organisers).  For example, when  MCA conducts a promotion, it may enter into a contractual arrangement with a mailing house, which will be subject to a contractual obligation to distribute on MCA's behalf information about its products, services or promotions.  If  MCA does disclose personal information to third party contractors under outsourcing or contracting arrangements,  MCA will take steps to ensure that those contractors:

–                 handle your personal information consistently with this Policy ;

–                 only use your personal information in order to provide the specific services or to perform the specific functions required by MCA; and

–                 store your personal information securely, and only for as long as is necessary to provide the required services or perform the required functions.

(b) Disclosures required or permitted by law

UM may also disclose personal information to individuals, corporations, organisations or governmental authorities without your consent if it is required to do so by a court of competent jurisdiction , or if the disclosure is permitted under existing law. .

(c) Disclosures to credit providers and credit-reporting agencies

If you purchase our goods or services,  MCA may disclose personal information to credit providers for credit related purposes such as credit-worthiness, credit rating, credit-reporting and fraud-checking.  If we disclose your personal information to credit providers you acknowledge that this information may be recorded on the credit information file that the external credit provider may maintain about you.

(d) Transfer of personal information overseas

From time to time  MCA transfers personal information to overseas companies, both in the  Universal Music group of companies and externally.  For example, this may occur in the course of booking overseas tours for artists contracted to MCA , or when we store personal information about customers, club members and competition entrants on servers that are hosted by a Universal Music company or an external offshore company.

If  MCA does transfer your personal information overseas, we will take steps to ensure your personal information is given the same privacy protection in the destination country.

(e) Personal information that you communicate or publish via  MCA  or Universal Music Group websites

 MCA recommends that you do not publish or communicate personal information accessible to the public via  MCA or Universal Music Group websites unless you want that information to be seen by others.

Should you choose to publish or communicate personal information, or select features on  MCA or Universal Music Group websites that allow you to display, publish or communicate personal information about yourself to the public via  such websites, you acknowledge that MCA  cannot control the use of such personal information by others. 

5. Access and Correction of Personal Information.

You have the right to ask  MCA to correct personal information about you that you think is inaccurate, incomplete or out of date.

If you wish to  to seek access to the personal information  MCA holds about you,  MCA asks that you make a request in writing to its Privacy Officer (contact details are set out in section 9 below).  Your request should state whether you are seeking access to all the personal information  MCA holds about you or to particular personal information (in which case you should specify that in your request).  You should also provide some form of identification (e.g. a photocopy of your driver’s licence or passport) so  MCA can verify that you are the person to whom the personal information relates.  You should also include details of how  MCA can contact you in case it needs to discuss your request.  If you need more information before making a formal request for access, please contact MCAs Privacy Officer, who can explain how  MCA will handle your access request and assist you in making that request.

 MCA will assume (unless you tell it otherwise) that your request relates to MCA's current records about you.  These current records will include personal information about you which is included in MCA's databases and in paper files, and which may be used by MCA  on a day to day basis.  To provide you with access to current personal information,  MCA  will ordinarily provide you with a print-out of the relevant personal information from its databases, or with photocopies of records which are held only on paper files.  If personal information about you (e.g. your name and address details) is duplicated across different databases, MCA will generally provide you with only one printout of this information.  Ordinarily, MCA  will not charge you for the cost of providing this type of access to its records, and it will generally respond to access requests of this type within 30 days of receiving your request.

For legal and administrative reasons,  MCA may also store records containing personal information in its archives.  You may seek access to the records held by  MCA which are not current records, but if you do so,  MCA may charge you for the cost of providing access.  It may also take  MCA longer to respond to your request.  Please contact the Privacy Officer to discuss your requirements.

If you think that any of the personal information  MCA holds about you is not accurate, complete or up to date, please provide MCA's Privacy Officer with your request for correction (contact details are set out in section 9 below).  It is MCA's policy to consider and respond to any requests for correction within 30 days of receiving the request.

If  MCA agrees that your personal information is not accurate, complete and up to date,  MCA will correct it for you.  If it does not agree with your view,  MCA will provide you with reasons for its view, and will provide you with an opportunity to make a statement of your view and have it included with the information.

6. Storage and Security of Personal Information.

 MCA takes reasonable steps to protect the personal information it holds and controls from such risks as loss, misuse, unauthorised access, destruction, modification or disclosure.  The means of protection  MCA uses includes, but is not limited to firewalls, password access, secure servers and encryption of credit card transactions.   MCA only allows authorised personnel to access personal information, and it is a condition of employment with  MCA that its employees maintain the confidentiality of personal information.

 MCA cannot guarantee the security of online transactions and communications sent by electronic means or post.  You are responsible for ensuring the confidentiality and security of, and for all activities which occur under, any username and/or password assigned to you by  MCA for the purpose of providing our goods or services and any purposes incidental to the provision of our goods and services (including without limitation any unauthorised use of your credit card).

7.  Destruction and de-identification of personal information

Unless a legal requirement requires otherwise, if  MCA no longer requires the personal information it has collected from you for the purpose for which it was collected, it will take reasonable steps to destroy or permanently de-identify your personal information.

8. Online Privacy Issues.

 MCA will apply this policy to all personal information it handles, whether collected online or otherwise.  To the extent that this Policy applies to online privacy issues, it is to be read as forming part of the terms of use for  MCA or Universal Musicj Group websites.  This section 8 is intended to provide more information about privacy for the users of  MCA or Universal Musicj Group websites.

(a) Online collection of personal and non-personal information

As outlined in section 3 above,  MCA collects personal information through  MCA or Universal Music Group  websites when you sign up to join one of its clubs or when you contact  MCA through its online enquiry forms.

 Such websites may also collect other information that may or may not be personal information.  Each time you visit sucha  websiteS, its server automatically recognises and stores your "address" (e.g. your domain name or internet protocol address), the type of internet browser you are using, the address of the site that "referred" you to the subject   websites and clickstream data.

In addition,the said  websites use cookies to track usage of its websites.  Most web browsers are set by default to accept cookies.  However, if you do not wish to receive any cookies you may set your browser to either prompt or refuse cookies.  Please note that rejecting cookies may mean that not all the functions on the said websites you visit will be  available to you.   MCA or the Universal Music Group uses cookies for tracking the statistics of its websites.  This allows  MCA to better understand its users and improve the layout and functionality of its websites.  This tracking is conducted in such a way as to ensure the anonymity of visitors to  said websites.  While the cookie may identify your computer, it should not identify you.

(b) Links to other websites

Sometimes  the said websites contain links to third party websites for your convenience and information.  You should be aware that when you access a non-Universal Music Groupo  website,  MCA is not responsible for the privacy practices or policies of that site.  MCA  suggests that you review the privacy policy of each site you visit, especially if you intend to provide any personal information via the site.

9. How to Contact MCA .

If you have any questions or comments about this privacy policy, if you wish to access any personal information  MCA holds about you, or if you wish to make a complaint about how MCA  has handled personal information about you, please contact 'MCAs Privacy Officer by one of the following methods:

by facsimile: (632) 9162551;

by email: mcamusic@umusic.com; or

–                 by letter: 34^th Floor, Raffles Corporate Center, Emerald Avenue, Ortigas Center, Pasig City.

10. Changes to this Privacy Policy.

This privacy policy may change from time to time.